K Number
K211736
Date Cleared
2021-09-05

(90 days)

Product Code
Regulation Number
882.5890
Reference & Predicate Devices
Predicate For
N/A
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

PMS (Mode 1~8)

It is intended to stimulate healthy muscles in order to improve and facilitate muscle performance.

TENS (Mode 9~25)

To be used for temporary relief of pain associated with sore and aching muscles in the shoulder, waist, back of the neck, arm, leg, and foot due to strain from exercise or normal household work activities by applying current to stimulate nerve.

Device Description

Electronic Muscle Stimulator is a portable and adapter powered multifunctional device, offering both Transcutaneous Electronic Nerve Stimulator (TENS) and Powered Muscle Stimulator (PMS) qualities.

Electronic Muscle Stimulator has 25 operation modes, which can give certain electrical pulse through 4 pcs of electrode pads placed on the skin to help users to enjoy body stimulation and 2 big electrode pads in Electrode Silicon Area for feet placed on the main unit to help users to enjoy sole stimulation.

The electronic stimulatory module has the operating elements of ON/OFF Switch, Display screen, Mode Selection key and Intensity Modification keys.

The models AST-300A and AST-300W have 9 buttons which is more than other models. Compared with other models, the "Time+" and "Time-" buttons are used to adjust the treatment time.

The LCD display screen can show selected mode, output intensity of body and/or sole, and time remaining of an application model. The device is equipped with accessories of electrode pads, electrode wire, adapter, remote controller. The electrode wire is used to connect the pads to the main unit; the adapter wire is used to connect the adapter to the device. The electrode pads are complying with the biocompatibility standards ISO 10993-5 (Cytotoxicity) and ISO 10993-10 (Irritation and Sensitization), are interchangeable.

AI/ML Overview

This document is a 510(k) Summary for an Electronic Muscle Stimulator, demonstrating substantial equivalence to a predicate device. It is not a report for an AI-powered medical device and therefore does not contain information typically found in such reports regarding acceptance criteria for AI performance, specific studies with test sets, expert ground truth establishment, MRMC studies, or training set details.

Based on the provided text, here's what can be extracted, and where limitations exist:

1. A table of acceptance criteria and the reported device performance:

The document doesn't explicitly state "acceptance criteria" in the context of AI performance metrics (like sensitivity, specificity, AUC). Instead, it compares the subject device's specifications to those of a predicate device to demonstrate substantial equivalence. The acceptance is implicitly shown by meeting the same or similar specifications as the already cleared predicate device, and demonstrating that any differences do not raise new safety or effectiveness issues.

Here is a table based on the "Elements of Comparison" between the Subject Device and Predicate Device, which serves as the "performance" for this type of device:

Acceptance Criteria (e.g., Predicate Device Performance)Reported Device Performance (Subject Device)Remark
Device Name and Model: Health Expert Electronic Stimulator Model: AST-300F, AST-300H, AST-300JElectronic Muscle Stimulator Model: AST-300A, AST-300N, AST-300S, AST-300T, AST-300V, AST-300W--
510(k) Number: K190673Applying (K211736)--
Intended Use (PMS): To stimulate healthy muscles to improve and facilitate muscle performance.SameSE (Substantially Equivalent)
Intended Use (TENS): Temporary relief of pain associated with sore and aching muscles in shoulder, waist, back, neck, arm, leg, foot due to strain from exercise or normal household work activities by applying current to stimulate nerve.SameSE
Power Source(s): Adaptor Input: 100-240Vac, 50-60Hz, 0.1A; Output: 5Vdc, 1A; Unit Input: 5Vdc, 1ASameSE
Method of Line Current Isolation: Type BF Applied PartSameSE
Patient Leakage Current (NC): AC: 54.5 µA, DC: 0 µAAC: 54.5 µA, DC: 0.5 µASE
Patient Leakage Current (SFC): AC: 120.0 µA, DC: 0 µAAC: 120.0 µA, DC: 0.6 µASE
Average DC current through electrodes (device on but no pulses): < 0.01 µASameSE
Number of Output Channels: 2SameSE
Number of Output Modes: 25SameSE
Output Intensity Level: 99 stepsSameSE
Synchronous or Alternating?: SynchronousSameSE
Method of Channel Isolation: Voltage Transform Isolation, "Body+" and "Body-" buttons for body channel, "Sole+" and "Sole-" buttons for feet channelSameSE
Regulated Current or Regulated Voltage?: Voltage ControlSameSE
Software/Firmware/Microprocessor Control?: YesYesSE
Automatic Overload Trip: NoNoSE
Automatic No-Load Trip: NoNoSE
Automatic Shut Off: YesYesSE
User Override Control: YesYesSE
Indicator Display (On/Off Status): YesYesSE
Indicator Display (Low Battery): NoNoSE
Indicator Display (Voltage/Current Level): YesYesSE
Timer Range: 25 min (default)AST-300N, AST-300S, AST-300T, AST-300V: 25 min (default); AST-300A and AST-300W: can adjust the time (5-25min)SE
Weight: 1.9Kg (Without accessories)Varies by model (e.g., AST-300A: 1.62kg, AST-300W: 1.99kg)SE Note (Differences do not raise safety/effectiveness issues)
Dimensions: 429.1mm x 426.6mm x 153.8mmVaries by model (e.g., AST-300A: 209.7x215.3x52.3mm, AST-300W: 464.7x419.6x181mm)SE Note (Differences do not raise safety/effectiveness issues)
Housing Materials and Construction: Main unit: ABS plasticSameSE
Waveform: Pulsed, symmetric, biphasicSameSE
Shape: Rectangular, with interphase intervalSameSE
Maximum Output Voltage: 44V±10% @ 500Ω; 80V±10% @ 2KΩ; 112V±20% @ 10KΩ44V±10% @ 500Ω; 80V±10% @ 2KΩ; 112V±10% @ 10KΩSE (Note: Subject device's 10KΩ tolerance is ±10% vs predicate's ±20%, meaning it's tighter, which is acceptable)
Maximum Output Current: 88mA±10% @ 500Ω; 40mA±10% @ 2KΩ; 11.2mA±10% @ 10KΩSameSE
Pulse width: 120µsSameSE
Pulse frequency: 77.3HzSameSE
Net Charge (per pulse): 0µC @ 500Ω; Method: Balanced waveformSameSE
Maximum Phase Charge: 10.56μC @ 500ΩSameSE
Maximum Average Current: 1.63mA @ 500ΩSameSE
Maximum Current Density (r.m.s): 0.0326mA/cm² @ 500ΩSameSE
Maximum Average Power Density: 0.0000266mW/cm² @ 500ΩSameSE
ON Time: 0.6sSameSE
OFF Time: 0.6sSameSE
Environment for operating: Temperature: 5 ~ 45° C; Humidity: 20 ~ 65% RHSameSE
Environment for storage: Temperature: 0 ~ 45°C, Humidity: 10 ~ 90% RH; Electrode Pad: 10~20°CSameSE
Biocompatibility: All user directly contacting materials are compliance with ISO10993-5 and ISO10993-10 requirements.SameSE
Electrical Safety: Comply with IEC 60601-1 and IEC 60601-2-10SameSE
EMC: Comply with IEC 60601-1-2SameSE

2. Sample sizes used for the test set and the data provenance:

  • Sample Size: Not applicable. This submission relies on substantial equivalence to an existing device, not a new clinical study.
  • Data Provenance: Not applicable for a typical "test set" as understood for AI performance. The provenances relate to the standards adherence (e.g., IEC, ISO standards for electrical safety, EMC, biocompatibility) through lab bench testing. The country of origin of the device manufacturer is China.

3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:

  • Not applicable. This device is an Electronic Muscle Stimulator, not a device that processes complex data (like medical images) requiring expert interpretation for ground truth.

4. Adjudication method (e.g., 2+1, 3+1, none) for the test set:

  • Not applicable. No test set requiring adjudication of findings is described.

5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance:

  • Not applicable. This is not an AI-assisted device.

6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:

  • Not applicable. This is not an AI algorithm.

7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):

  • For this type of device, "ground truth" is established by adherence to recognized performance and safety standards (e.g., IEC 60601 series for electrical safety, ISO 10993 series for biocompatibility). The testing mentioned (Electrical safety, EMC, Biocompatibility, Usability, Software V&V) are based on these established engineering and safety requirements.

8. The sample size for the training set:

  • Not applicable. This device does not use an AI model that requires a training set.

9. How the ground truth for the training set was established:

  • Not applicable.

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Image /page/0/Picture/0 description: The image contains two logos. On the left is the Department of Health & Human Services logo, which features a stylized caduceus. To the right of that is the FDA logo, which is a blue square with the letters "FDA" in white, followed by the words "U.S. FOOD & DRUG ADMINISTRATION" in blue.

September 5, 2021

Shenzhen OSTO Technology Company Limited % Cassie Lee Manager Guangzhou GLOMED Biological Technology Co., Ltd. Room 2231, Building 1, Ruifeng Center, Kaichuang Road Huangpu District Guangzhou City Guangdong, China

Re: K211736

Trade/Device Name: Electronic Muscle Stimulator (Model: AST-300A, AST-300N, AST-300S, AST-300T, AST-300V, AST-300W) Regulation Number: 21 CFR 882.5890 Regulation Name: Transcutaneous Electrical Nerve Stimulator For Pain Relief Regulatory Class: Class II Product Code: NUH, NGX Dated: May 31, 2021 Received: June 7, 2021

Dear Cassie Lee:

We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.

If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.

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Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting of medical device-related adverse events) (21 CFR 803) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.

For comprehensive regulatory information about medical devices and radiation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).

Sincerely.

Pamela Scott Assistant Director DHT5B: Division of Neuromodulation and Physical Medicine Devices OHT5: Office of Neurological and Physical Medicine Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health

Enclosure

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Indications for Use

510(k) Number (if known) K211736

Device Name

Electronic Muscle Stimulator (Model: AST-300A, AST-300N, AST-300T, AST-300T, AST-300V, AST-300W)

Indications for Use (Describe)

PMS (Mode 1~8)

It is intended to stimulate healthy muscles in order to improve and facilitate muscle performance.

TENS (Mode 9~25)

To be used for temporary relief of pain associated with sore and aching muscles in the shoulder, waist, back of the neck, arm, leg, and foot due to strain from exercise or normal household work activities by applying current to stimulate nerve.

Type of Use (Select one or both, as applicable)

Prescription Use (Part 21 CFR 801 Subpart D)

X Over-The-Counter Use (21 CFR 801 Subpart C)

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510(k) Summary for K211736

This summary of 510(K) safety and effectiveness information is being submitted in accordance with the requirement of 21 CFR 807.92.

1. Submitter's Information

  • 510(k) Owner's Name: Shenzhen OSTO Technology Company Limited �
  • Establishment Registration Number: 3011564440 �
  • � Address: No.43 Longfeng Road, Xinsheng Community, Longgang Street, Longgang District, Shenzhen City, Guangdong Province, China
  • Tel: +86-755-29769546 �
  • � Fax: +86-755-29769540
  • Contact Person: Li Yang (General Manger) �
  • � Email: annaosto@163.com

Application Correspondent: 2.

  • � Contact Person: Ms. Cassie Lee
  • Guangzhou GLOMED Biological Technology Co., Ltd. �
  • � Address: 2231, Building 1, Rui Feng Center, Kaichuang Road, Huangpu District, Guangzhou, Guangdong, China
  • Tel: +86 20 8266 2446 �
  • Email: regulatory@glomed-info.com

3. Subject Device Information

  • Electronic Muscle Stimulator � Trade Name:
  • Electronic Stimulator Common Name: �
  • Stimulator, Nerve, Transcutaneous, Muscle, Powered, For �
    • Classification name: Muscle Conditioning, Over-The-Counter
  • Neurology, Physical Medicine Review Panel: �

ll

  • NUH, NGX Product Code: �
  • � Regulation Class:
  • 882.5890, 890.5850 Regulation Number: �

4. Predicate Device Information

  • Sponsor Shenzhen OSTO Technology Company Limited � Health Expert Electronic Stimulator � Device Name and Model Model: AST-300F, AST-300H, AST-300J

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  • 510(k) Number K190673
  • NUH, NGX Product Code �
  • � Regulation Number 882.5890, 890.5850
  • � Requlation Class II

2. Device Description

Electronic Muscle Stimulator is a portable and adapter powered multifunctional device, offering both Transcutaneous Electronic Nerve Stimulator (TENS) and Powered Muscle Stimulator (PMS) qualities.

Electronic Muscle Stimulator has 25 operation modes, which can give certain electrical pulse through 4 pcs of electrode pads placed on the skin to help users to enjoy body stimulation and 2 big electrode pads in Electrode Silicon Area for feet placed on the main unit to help users to enjoy sole stimulation.

The electronic stimulatory module has the operating elements of ON/OFF Switch, Display screen, Mode Selection key and Intensity Modification keys.

The models AST-300A and AST-300W have 9 buttons which is more than other models. Compared with other models, the "Time+" and "Time-" buttons are used to adjust the treatment time.

The LCD display screen can show selected mode, output intensity of body and/or sole, and time remaining of an application model. The device is equipped with accessories of electrode pads, electrode wire, adapter, remote controller. The electrode wire is used to connect the pads to the main unit; the adapter wire is used to connect the adapter to the device. The electrode pads are complying with the biocompatibility standards ISO 10993-5 (Cytotoxicity) and ISO 10993-10 (Irritation and Sensitization), are interchangeable.

5. Intended Use / Indications for Use

PMS (Mode 1~8)

It is intended to stimulate healthy muscles in order to improve and facilitate muscle performance.

TENS (Mode 9~25)

To be used for temporary relief of pain associated with sore and aching muscles in the shoulder, waist, back, back of the neck, arm, leg, and foot due to strain from exercise or normal household work activities by applying current to stimulate nerve.

6. Test Summary

6.1 Non-clinical testing was conducted to verify that the subject device met all design specifications, demonstrated safety based on current industry standards, and to

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demonstrate substantial equivalence to the predicate. The following tests were performed:

Electronic Muscle Stimulator has been evaluated the safety and performance by lab bench testing as following:

  • Electrical safety test according to IEC 60601-1, IEC 60601-1-11 and IEC 60601-2-10 � standards
  • � Electromagnetic compatibility test according to IEC 60601-1-2 standard
  • � Biocompatibility test according to ISO 10993-5 and ISO 10993-10 standards
  • � Usability test according to IEC 62366-1 standard
  • � Software verification and validation test according to the requirements of the FDA "Guidance for Pre-Market Submissions and for Software Contained in Medical Devices"

6.2 Summary of Clinical Performance Test

No clinical study is included in this submission.

7. Comparison to predicate device and conclusion

The technological characteristics, features, specifications, materials, mode of operation, and intended use of Electronic Muscle Stimulator is substantially equivalent to the predicate devices quoted above.

The differences between the subject device and predicate devices do not raise new issues of safety or effectiveness.

Elements of ComparisonSubject DevicePredicate DeviceRemark
Device Name and ModelElectronic MuscleStimulatorModel: AST-300A,AST-300N, AST-300S,AST-300T , AST-300V,AST-300WHealth Expert ElectronicStimulatorModel: AST-300F,AST-300H, AST-300J--
510(k) NumberApplyingK190673--
Intended UsePMS (Mode 18)It is intended to stimulatehealthy muscles in orderto improve and facilitatemuscle performance.TENS (Mode 925)PMS (Mode 18)It is intended to stimulatehealthy muscles in order toimprove and facilitatemuscle performance.TENS (Mode 925)SE
Elements of ComparisonSubject DevicePredicate DeviceRemark
To be used for temporaryrelief of pain associatedwith sore and achingmuscles in the shoulder,waist, back, back of theneck, arm, leg, and footdue to strain fromexercise or normalhousehold work activitiesby applying current tostimulate nerve.To be used for temporaryrelief of pain associatedwith sore and achingmuscles in the shoulder,waist, back, back of theneck, arm, leg, and foot dueto strain from exercise ornormal household workactivities by applyingcurrent to stimulate nerve.
Power Source(s)Adaptor Input:100-240Vac, 50-60Hz,0.1AOutput: 5Vdc, 1AUnit Input: 5Vdc, 1AAdaptor Input: 100-240Vac,50-60Hz, 0.1AOutput: 5Vdc, 1AUnit Input: 5Vdc, 1ASE
-Method of Line Current IsolationType BF Applied PartType BF Applied PartSE
Patient LeakageCurrentNCAC: 54.5 $\mu$ A, DC: 0 $\mu$ AAC: 54.5 $\mu$ A, DC: 0.5 $\mu$ ASE
SFCAC:120.0 $\mu$ A, DC: 0 $\mu$ AAC:120.0 $\mu$ A, DC: 0.6 $\mu$ A
Average DC current throughelectrodes when device is on butno pulses are being applied< 0.01 $\mu$ A< 0.01 $\mu$ ASE
Number of OutputChannels:22SE
Number of Output Modes2525SE
Output Intensity Level99 steps99 stepsSE
Synchronous or Alternating?SynchronousSynchronousSE
Elements of ComparisonSubject DevicePredicate DeviceRemark
Method of Channel IsolationVoltage TransformIsolation"Body+" and "Body-"buttons for body channel,"Sole+" and "Sole-"buttons for feet channelVoltage Transform Isolation"Body+" and "Body-"buttons for body channel,"Sole+" and "Sole-" buttonsfor feet channelSE
Regulated Current or RegulatedVoltage?Voltage ControlVoltage ControlSE
Software/Firmware/MicroprocessorControl?YesYesSE
Automatic Overload TripNoNoSE
Automatic No-Load TripNoNoSE
Automatic Shut OffYesYesSE
User Override ControlYesYesSE
Indicator DisplayOn/Off StatusYesYesSE
Low BatteryNoNoSE
Voltage/Current LevelYesYesSE
Timer RangeAST-300N, AST-300S,AST-300T andAST-300V: 25 min(default);AST-300A andAST-300W: can adjustthe time (5-25min)25minSE
WeightAST-300A: 1.62kgAST-300N: 1.5kgAST-300S: 1.23kgAST-300T: 1.92kgAST-300V: 1.93kgAST-300W: 1.99kg1.9Kg (Withoutaccessories)SE Note
DimensionsAST-300A:429.1mm x 426.6mm x153.8mmSE Note
Elements of ComparisonSubject DevicePredicate DeviceRemark
209.7215.352.3mmAST-300N:403.7402.647.3mmAST-300S:345.5316.174.2mmAST-300T:401.9401.3158.9mmAST-300V:464.6419.6181.0mm
AST-300W:464.7419.6181mm
Housing Materials andConstructionMain unit: ABS plasticMain unit: ABS plasticSE
WaveformPulsed, symmetric,biphasicPulsed, symmetric, biphasicSE
ShapeRectangular, withinterphase intervalRectangular, withinterphase intervalSE
Maximum Output Voltage44V±10% @ 500Ω44V±10% @ 500ΩSE
80V±10% @ 2KΩ80V±10% @ 2KΩSE
112V±10% @ 10KΩ112V±20%@ 10KΩSE
Maximum Output Current88mA±10% @ 500Ω88mA±10% @ 500ΩSE
40mA±10% @ 2KΩ40mA±10% @ 2KΩSE
11.2mA±10% @ 10KΩ11.2mA±10% @ 10KΩSE
Pulse width120µs120µsSE
Pulse frequency77.3Hz77.3HzSE
Net Charge (per pulse)0µC @ 500ΩMethod: Balancedwaveform0µC @ 500ΩMethod: BalancedwaveformSE
Maximum Phase Charge10.56μC @ 500Ω10.56μC @ 500ΩSE
Maximum Average Current1.63mA @ 500Ω1.63mA @ 500ΩSE
Elements of ComparisonSubject DevicePredicate DeviceRemark
Maximum Current Density(r.m.s )0.0326mA/cm² @ 500Ω0.0326mA/cm2 @500ΩSE
Maximum Average Power Density0.0000266mW/cm² @500Ω0.0000266mW/cm² @500ΩSE
ON Time0.6s0.6sSE
OFF Time0.6s0.6sSE
Environment for operatingTemperature: 5 ~ 45° CHumidity: 20 ~ 65% RHTemperature: 5 ~ 45°CHumidity: 20 ~ 65% RHSE
Environment for storageTemperature: 0 ~ 45°C,Humidity: 10 ~ 90% RHElectrode Pad: 10~20°CTemperature: 0 ~ 45°C,Humidity: 10 ~ 90% RHElectrode Pad: 10~20°CSE
BiocompatibilityAll user directlycontacting materials arecompliance withISO10993-5 andISO10993-10requirements.All user directly contactingmaterials are compliancewith ISO10993-5 andISO10993-10 requirements.SE
Electrical SafetyComply with IEC60601-1 and IEC60601-2-10Comply with IEC 60601-1and IEC 60601-2-10SE
EMCComply with IEC60601-1-2Comply with IEC 60601-1-2SE

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Comparison in Detail(s):

Note:

Although the "Weight" and "Dimensions" are a little different from the predicate device, but the differences will not raise any safety or effectiveness issue.

Final Conclusion:

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The subject devices "Electronic Muscle Stimulator (Model: AST-300A, AST-300N, AST-300S, AST-300T, AST-300V, AST-300W) are Substantial Equivalent to the predicate device K190673.

8. Date of the summary prepared: September 2, 2021

§ 882.5890 Transcutaneous electrical nerve stimulator for pain relief.

(a)
Identification. A transcutaneous electrical nerve stimulator for pain relief is a device used to apply an electrical current to electrodes on a patient's skin to treat pain.(b)
Classification. Class II (performance standards).